Office of Compensation Analysis and Support 

Program Evaluation Plan

Document Number: OCAS-PEP-012 

Effective Date: 3/29/2007 

Revision No. 0

Evaluation of Highly Insoluble Plutonium Compounds Page 1 of 6 

Author: Signature on file Date: 3/29/2007 Dave Allen, HP Team Leader 

Approval: Signature on file Date: 3/29/2007 J.W. Neton, Associate Director for Science 

Supersedes: None 

RECORD OF ISSUE/REVISIONS 

ISSUE 

AUTHORIZATION 

DATE 

3/29/2007

EFFECTIVE 

DATE 

3/29/2007 

REV. NO. 

0 

DESCRIPTION 

New document to evaluate the affect of 

OTIB-0049, Highly Insoluble Plutonium 

Compounds on previously completed 

claims. 

1.0 Description

In the first version of the Rocky Flats Plant (RFP) Internal TBD (Jan 2004), it was noted 

that highly insoluble forms of plutonium were generated during the Rocky Flats fires. In 

response to the need to assess claims with potential exposure to this material, ORAUTOTIB-0049 was developed. ORAUT-OTIB-0049 delineates the methods for assessing 

potential exposure to highly insoluble forms of plutonium, not only from the RFP fires, 

but at other sites in the complex that may have worked with this material. 

2.0 Issue Evaluation

The issuance of ORAUT-OTIB-0049 on February 6, 2007 provided guidance for 

assessing claims with potential exposure to highly insoluble forms of plutonium. 

ORAUT-OTIB-0049 does not propose a new type of material for general modeling 

purposes or propose a new variation of the lung model. Rather, to account for the 

difference in organ doses, the TIB analysis developed empirical “dose adjustment 

factors” from selected cases from RFP and Hanford that exhibited Type Super S behavior 

following intakes of 239Pu mixtures. For intakes calculated from urinary excretion data, a 

bounding analysis is implemented as an intake adjustment factor rather than a defined 

change in ICRP model parameters. 

Due to the increased doses assigned to workers exposed to Type Super S plutonium, 

previously completed claims that were assigned plutonium doses at sites where this 

material is potentially available for exposure need to be reexamined to determine the 

impact (if any) on the dose assessment. 
Office of Compensation Analysis and Support

Document Number: OCAS-PEP-012 Program Evaluation Plan 

Effective Date: 3/29/2007 Revision No. 0 Page 2 of 6 

3.0 Plan for Resolution or Corrective Action

Parameters for inclusion: 

1. Probability of Causation (PC) less than 50% 

2. Assessment of plutonium in most recent Dose Reconstruction version. 

3. Most recent version approved by OCAS on or prior to February 6, 2007 and 

presently not in process 

4. Potential for highly insoluble form of plutonium possible at site. 

Steps for determining included claims (database search portion): 

1. Select only those claims with PC less than 50% 

2. Assessment of plutonium in the most recent version of the dose reconstruction 

that may have applicability to OTIB-0049. The completed claims were 

electronically searched for the 5 following situations 

a. Lung claims (not just lung cancers, but all claims where lung is organ of 

interest) and thoracic lymph nodes [LN(Th)] claims where OTIB-0018 

was used as an overestimate. Only the lung and LN(Th) claims need to be 

examined since OTIB-0018 is based on air concentrations and only these 

organs must be adjusted per OTIB-0049. 

b. Any claim that has an IMBA file for Pu-239. This will be accomplished 

by searching for IMBA files with “pu” in the title and removing those 

claims that only have IMBA runs for isotopes other than Pu-239. 

c. Any claim where Chronic Annual Dose Workbook CADW was used with 

Pu-239 as an isotope of interest. This will include any claim where the 

environmental portion of the CADW tool includes Pu-239 in the dose 

assignment or plutonium was only assessed as part of a recycled uranium 

matrix. Although the environmental assignment of Pu-239 will only apply 

to lung and LN(Th) claims for OTIB-0049 dose adjustments for the same 

reason as OTIB-0018 (environmental intakes are based on resuspension 

and air monitoring), all CADW claims will be examined for this issue in a 

later step (the electronic search did not lend itself to this level of 

discrimination). 

d. Any claim where a stand-alone internal environmental tool was used for 

lung and LN(Th) (to cover the timeframe before CADW was used). Only 

lung and LN(Th) are required for the same reason as for OTIB-0018. 

e. Any claim with the text “plut” or “pu-” in the DR Report. This is a final 

“catch-all” to ensure any claims that may not have had all the supporting 

files moved to the AR folder are also captured. These claims will be 

compared to the claims from all previous criteria and any duplicates 

removed. 

3. Select only claims approved by OCAS on or prior to February 6, 2007 and are not 

presently in process (due to reasons such as DOL-returned based on new cancer 
Office of Compensation Analysis and Support

Document Number: OCAS-PEP-012 Program Evaluation Plan 

Effective Date: 3/29/2007 Revision No. 0 Page 3 of 6 

diagnoses). The following Dose Reconstruction Tracking System (DRTS) 

statuses are removed: 

a. DR in Progress 

b. DR Complete 

c. PR in Progress 

d. Peer Review Complete (Ready for OCAS) 

e. OCAS Review in Progress 

f. Returned from DOL – Comments Pending 

g. Returned from DOL – Comments Received 

4. Remove those claims where employment was only at sites where Type Super S 

plutonium material was not feasible. For example, OTIB-0049 will not apply to 

the gaseous diffusion sites since the only plutonium on-site was a minor 

constituent by mass in another matrix, such as in recycled uranium – see 

Attachment A for a list of sites where Type Super S has been determined to be 

considered and sites where it has been determined to be not applicable. The 

attachment is not meant to be a comprehensive list of sites where Type Super S 

should be considered or excluded, but rather a list with enough sites to categorize 

all the claims that have met the criteria defined above. 

These criteria were used to generate the list of potentially affected claims (total = 3,451 

claims). 

The affects of OTIB-0049 can be quantified to the point of allowing an additional 

selection criteria based on the original Probability of Causation of the claim. The 

additional selection criteria are: 

a. PC≥20% for claims with organs other than lung or LN(Th) based upon the 

correction factor of 4 derived in Att. C of ORAUT-OTIB-0049 and the 

discussion below on PC. 

The PC selection criteria values are based on the fact that the dose estimate is used to 

determine the Excess Relative Risk (ERR). The Probability of Causation (PC) is 

determined directly from the ERR. The relationship is: 

PC = [ERR/(1+ERR)]*100% 

From this equation it can be seen that an ERR of 1 is required to yield a PC of 50%. For 

a given scenario of time since exposure, age at diagnosis, type of cancer, type of 

radiation, etc., the ERR varies essentially linearly with dose. Therefore, it is possible to 

assess the change in PC on a particular case if the change in dose is known and it is the 

same for all sources of dose. This, of course, is not the case for the potential changes in 

dose due to the application of OTIB-0049 since only internal dose due to plutonium 

changed. Therefore, in the evaluation, the changes will be assessed as if all the doses 
Office of Compensation Analysis and Support

Document Number: OCAS-PEP-012 Program Evaluation Plan 

Effective Date: 3/29/2007 Revision No. 0 Page 4 of 6 

increased by a factor of four. This will overestimate the magnitude of the change and 

produce a larger than necessary group of claims to evaluate further. 

Based on the equation above, adjusting the ERR by a factor of 4, an original PC of 20% 

would now result in a PC of 50%. Thus, a lower selection criterion of 20% has been 

selected for claims without lung or LN(Th) as a target organ. 

These criteria were used to reduce the list of potentially affected claims to 2,725. 

The potentially affected claims can be further reduced with the following manual 

selection criteria: 

1. Document those claims where CADW was used only for environmental intakes of 

plutonium for all organs other than the lung and LN(Th) or as part of a recycled 

uranium matrix. As discussed in steps 1c and 1d in the database search section, 

only the lung and LN(Th) claims for environmental intakes will need to be 

examined for potential dose impact of Type Super S Pu material. 

2. Document those claims where none of the appropriate criteria are met, but the 

computer search could not be defined more narrowly without potentially 

screening out appropriate claims. This would include claims where the text “plut” 

or “pu-“ was in the DR Report, but no other Super S criteria are met, etc. 

Evaluation of the remaining claims will start with those having the highest original POC. 

As these claims are completed, it is possible that a point will be reached in which it is 

clear no additional claims will reach a POC of 50%. If this occurs, that point will be 

documented in the Program Evaluation Report and the remaining claims will not be 

evaluated. It is likely that this will require different points for the different target organs 

and possibly other factors. 

After the potential affected claims have been evaluated, a Program Evaluation Report 

(PER) will be written to summarize the results. As part of the report, claims that were 

not evaluated further due to the POC cut point will be reviewed to determine if they are 

also affected by another PER. The PER will contain additional analysis for these cases 

including additional evaluations if necessary. 
Office of Compensation Analysis and Support

Document Number: OCAS-PEP-012 Program Evaluation Plan 

Effective Date: 3/29/2007 Revision No. 0 Page 5 of 6 

4.0 References 

1. ORAUT (Oak Ridge Associated Universities Team), ORAUT-TKBS-0011-5, 

Technical Basis Document for the Rocky Flats Plant – Occupational Internal 

Dose, Rev 00, January 12, 2004. 

2. ORAUT (Oak Ridge Associated Universities Team), ORAUT-OTIB-0049, 

Estimating Doses for Plutonium Strongly Retained in the Lung, Rev 00, February 

6, 2007. 

3. ORAUT (Oak Ridge Associated Universities Team), ORAUT-OTIB-0018, 

Technical Information Bulletin: Internal Dose Overestimates for Facilities with 

Air Sampling Programs, Rev 01, August 9, 2005. 
Office of Compensation Analysis and Support

Document Number: OCAS-PEP-012 Program Evaluation Plan 

Effective Date: 3/29/2007 Revision No. 0 Page 6 of 6 

Attachment A 

Sites where Type Super S is to be considered or excluded for this PEP 

Consider Super S Exclude from Super S

Albuquerque Operations Office Allied Chemical (based on SEC) 

Amchitka Armour Research Foundation 

ANL-East Baker-Perkins 

ANL-West Bethlehem Steel 

Area IV Santa Susana Bliss & Laughlin Steel 

Battelle (King and/or W. Jefferson) BONUS Reactor 

Brookhaven Bridgeport Brass 

Clarksville BWXT, Inc. 

Conn. Aircraft Nuclear Eng. Lab Canoga Ave Facility 

General Atomics Clinton Eng. Works 

GE-Evendale (Ohio) Combustion Engineering 

GE-Vallecitos De Soto 

Hanford (PNNL) Downey Facility 

INEEL Extrusion Plant (RMI) 

LANL Fernald (FMPC) 

LBNL Harshaw 

LLNL Heppenstall Company 

Mound Iowa Ordinance Plant 

Nevada Site Office Jessop Steel 

NTS K-25 

NUMEC Kansas City Plant 

Pantex Landis Machine Tool Company 

Peek Street Mallinckrodt 

Rocky Flats Medina 

Salmon Nuclear Oak Ridge Hospital 

SLAC ORISE 

Sandia National Lab (SNL) Paducah 

SNL-Livermore Pinellas 

SPRU (Knolls) Portsmouth 

Savannah River Site Reed Rolled Thread Company 

Tonopah Test Site S-50 

West Valley SAM Laboratories, Columbia University 

Westinghouse Nuclear Fuels Division Seymour Specialty Wire 

W.R. Grace Simonds Saw and Steel 

X-10 (ORNL) Superior Steel 

Torrington Company 

U.S. Steel Corporation 

Vitro Manufacturing 

Weldon Spring 

Westinghouse Atomic Power Devel. Plant 

Y-12